Case Digest (G.R. No. 130931)
Facts:
People of the Philippines v. Erick Macahia, Redentor Macahia and Reynaldo Macahia, G.R. No. 130931, May 19, 1999, the Supreme Court Third Division, Panganiban, J., writing for the Court. The criminal Information charged Erick Macahia, Redentor Macahia and Reynaldo Macahia with murder for the September 12, 1994 killing of Cenon Gonzales; the Information alleged conspiracy and that the killing was qualified by evident premeditation and treachery. On arraignment Erick and Redentor pleaded not guilty; Reynaldo remained at large and trial proceeded as to Erick and Redentor only.At the Regional Trial Court (Quezon City), Judge Diosdado Madarang Peralta tried the case. Prosecution eyewitness Loven Magtibay testified that he saw the three accused gang up on the victim, with Erick holding the victim’s neck and firing a single gunshot to the head while Redentor and Reynaldo restrained the victim. The medico-legal officer testified to a single penetrating gunshot wound to the left occipital region and multiple abrasions; a slug was recovered. The defense presented denial and an alibi: Erick and Redentor maintained they were in Tanauan, Batangas celebrating their parents’ wedding anniversary; family members and a provincemate so testified.
On June 17, 1997 the trial court rendered a decision finding Erick and Redentor guilty beyond reasonable doubt of murder (Article 248, Revised Penal Code), sentencing each to reclusion perpetua and ordering indemnity of P74,000 as actual damages, P50,000 as moral damages, and P50,000 for the death. The court found treachery and abuse of superior strength as qualifying circumstances and also found conspiracy. Because of the penalty imposed, the appeal was taken directly to the Suprem...(Pro-only)
Issues:
- Did the trial court err in believing the prosecution witness and assessing witness credibility?
- Was the prosecution’s evidence sufficient to convict Erick and Redentor of murder beyond reasonable doubt?
- Was the killing properly characterized as murder qualified by treachery and abuse of superior strength, and was there conspiracy?
- Were the awards of actual and moral damages p...(Pro-only)
Ruling:
- (Pro-only)
Ratio:
- (Pro-only)
Doctrine:
- (Pro-only)